1.4 Which standard sent you here: silica, lead, asbestos

1 One program, many triggers

1910.134 is written as a general standard: it tells you how to run a respirator program, not when a respirator is needed for any particular substance. The substance-specific standards in Subpart Z supply the trigger, and then hand the program back.

The clearest example is silica. 29 CFR 1926.1153(e)(2): where respirator use is required by the section, the employer shall institute a respiratory protection program in accordance with 29 CFR 1910.134. That is the whole mechanism — the silica standard decides whether and what, and 1910.134 decides how.

Silica adds a second wrinkle that no other standard has. Table 1 of 1926.1153 specifies the required respirator and minimum assigned protection factor for each of eighteen construction tasks, split by duration and by whether the work is indoors or outdoors. Implement the specified controls fully and properly and (e)(3) treats you as complying with the respirator selection requirements of 1910.134(d)(1)(iii) and (d)(3) for silica — you do not have to assess exposures to pick the respirator. Everything else in 1910.134 still applies: medical evaluation, fit testing, training, the written program.

2 Lead: respirators before the sampling comes back

The lead standard for construction takes a different route, and it is worth knowing because it puts respirators on people before anyone has measured anything.

29 CFR 1926.62(d)(2) lists tasks that, where lead is present, are presumed to exceed the permissible exposure limit until an exposure assessment documents otherwise. Manual demolition, manual scraping, manual sanding, heat gun applications and power tool cleaning with dust collection are presumed above the 50 µg/m³ PEL and not more than ten times it. A second list — lead-containing mortar, lead burning, rivet busting, power tool cleaning without dust collection, cleanup with dry expendable abrasives, abrasive blasting enclosure movement and removal — is presumed above 500 µg/m³. A third — abrasive blasting, welding, cutting and torch burning on lead-coated structures — is presumed above 2,500 µg/m³, fifty times the PEL.

Paragraph (d)(2)(v) then requires interim protection for anyone doing those tasks: appropriate respiratory protection, protective work clothing and equipment, change areas, hand washing facilities, biological monitoring, and training. The respirator arrives on the first shift, on a presumption, and 1910.134 comes with it.

3 Asbestos: respirators as a supplement, never a substitute

29 CFR 1926.1101 sets a permissible exposure limit of 0.1 fiber per cubic centimeter as an 8-hour TWA and an excursion limit of 1.0 f/cc over any 30-minute period. Its structure puts respirators firmly second.

Paragraph (g)(1) requires, in all operations covered by the section and regardless of the measured exposure level, HEPA-filtered vacuum cleaners, wet methods or wetting agents, and prompt cleanup and disposal of waste in leak-tight containers. Paragraph (g)(2) adds the controls used to achieve the limits, and (g)(2)(v) states the principle: where the feasible engineering and work practice controls are not sufficient to reduce exposure to or below the limits, the employer shall use them to reduce exposure to the lowest levels attainable by those controls, and shall supplement them with respiratory protection under paragraph (h).

That word — supplement — is the same idea as 1910.134(a)(1), written into a substance standard. Asbestos also carries four absolute prohibitions at (g)(3) that no respirator lifts: high-speed abrasive disc saws without point-of-cut ventilation or HEPA-filtered enclosure; compressed air unless used with an enclosed system capturing the dust cloud; dry sweeping, shoveling or other dry cleanup; and employee rotation as a means of reducing exposure.

4 Where else respirators are decided for you

The HAZWOPER line is worth reading twice. 1910.120(q)(3)(iv): employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard shall wear positive pressure self-contained breathing apparatus while engaged in emergency response, until the individual in charge of the incident command system determines through the use of air monitoring that a decreased level of respiratory protection will not result in hazardous exposures.

5 Construction and general industry: what actually differs

For respiratory protection itself, almost nothing. 29 CFR 1926.103 adopts 1910.134 for construction work; the nine program elements, the medical evaluation, the fit testing and the training are identical.

What differs is the surrounding rules that decide when a respirator is needed. Exposure limits sit in 1910.1000 for general industry and 1926.55 for construction. The silica standards are split — 1926.1153 for construction with its Table 1, and 1910.1053 for general industry and maritime with the same 50 µg/m³ PEL and 25 µg/m³ action level but no Table 1 and a regulated-area requirement instead. Lead is 1926.62 in construction and 1910.1025 in general industry. Asbestos is 1926.1101 and 1910.1001.

So the practical question on a mixed site is not “which respirator standard” — it is one standard — but “which substance standard, and therefore which trigger and which specified respirator”.

6 Building the hazard list your program rests on

Every element of a respiratory protection program traces back to one table: the list of tasks that put someone in a respirator, and why. Build it before you write anything else.

1. 1
   List the tasks, not the job titles. Tuckpointing the north elevation is a task; “masons” is not.
2. 2
   Name the contaminant and its physical form — particulate, gas, vapor, or a combination — because that decides the whole family of respirator.
3. 3
   Record the basis: air monitoring, objective data, Table 1 of 1926.1153, a presumed-exposure task under 1926.62(d)(2), or “not estimable, treated as IDLH” under (d)(1)(iii).
4. 4
   Record the respirator and the cartridge, and for gases and vapors the ESLI or the change schedule and the data behind it, as (d)(3)(iii) requires.

That table is the first section of any usable written program — and a free template built on the nine elements of (c)(1) is at the respiratory protection program generator.